Smith's Criminal Case Compendium
Table of Contents
Criminal Procedure
Indictment & Pleading Issues
Evidence
Criminal Offenses
Drug Offenses
State v. Bell, 221 N.C. App. 535 (Jul. 17, 2012)
The trial court did not err by finding that the defendant consented to a search of his residence. The court rejected the defendant’s argument that the trial court must make specific findings regarding the voluntariness of consent even when there is no conflict in the evidence on the issue. Here, there was a conflict regarding whether the defendant gave consent, not whether if given it was voluntary.